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Under Section 32 (2) of BP Blg. 29, MTC shall exercise exclusive original jurisdiction over all offenses with imprisonment not exceeding 6 years "irrespective of the amount of the amount of fine." According to Administrative Circular No. 09-94, The amended version of Section 32 (2) is applicable if the offense is punishable by imprisonment or fine or both. If the offense is punishable by fine only, the original version of Section 32 applies is applicable. Under this old provision, MTC shall exercise exclusive original jurisdiction over all offenses with a fine not exceeding P4,000.
Section 1 (4) of the Revised Rules on Summary Procedure provides that this rule shall govern criminal cases where the penalty prescribed by law for the offense charged is imprisonment not exceeding 6 months or a fine not exceeding P1,000 or both.
For purposes of determining the jurisdiction of MTC where the penalty prescribed for the offense is both imprisonment and fine, the amount of fine should be disregarded because of the phrase “irrespective of the amount of fine” in Section 32 of BP Blg 129.
For purposes of determining the applicability of summary procedure where the penalty prescribed is both imprisonment and fine, the amount of fine should not be disregarded since the phrase “irrespective of the amount of fine” is not found in Section 1 (4) of the Revised Rules on Summary Procedure. What is explicit under provision is the mandate that to place a criminal case under the summary rules both, fine and imprisonment must not exceed the limits provided for under the rule.
Moreover, in conjunction with imprisonment, a fine is as much a principal penalty as the imprisonment. Neither is subordinate to the other (People v. Crisostomo, G.R. No. L-16945, August 31, 1962) .” Hence, the penalty of imprisonment and fine should not be split into two (People v. Cuello, G.R. No. L-14307, March 27, 1961) for purposes of determining the coverage of the Rules on Summary Procedure.
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